IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF SOUTH CAROLINA
) Cynthia Yaeger, O.D.; Individually and in their ) capacity as Clinical Director for TLC The Laser ) Eye Center (Institute), Inc.;
Robert Arffa, M.D.; David K. Aymond, M.D.; )
David Boes, M.D.; Stan Braverman, M.D.;
or in part, to the automatic stay of 11 U.S.C. \u00a7362 arising out of their Chapter 11 cases pending in the United State Bankruptcy Court for the District of Delaware. Plaintiffs presently intend to move the Bankruptcy Court for relief from that stay in order to amend the Complaint in this case to include the parent corporations as named defendants and proceed against them at that time. Currently, though, the automatic stay is in effect and nothing in this Complaint or any other document filed by Plaintiffs is intended or shall be deemed to be an action against the corporate parent debtors, their bankruptcy estates, or their property or property of their estates.
That the Defendants TLC LASIK Centers as listed above, (hereinafter collectively referred to as TLC LASIK Centers) are corporations organized and existing under the laws of various states within the United States who individually and through their respective agents, servants, employees, and/or in combination with independent contractor surgeons perform 1) ophthalmology, 2) optometry, and 3) LASIK surgery; that further the LASIK Eye Centers are, upon information and belief, direct or indirect wholly owned subsidiaries of TLC Vision Corporation1 through which TLC Vision Corp operates and conducts the business described above.
That the Defendants TLC Clinical Directors as listed above (hereinafter collectively referred to as Clinical Directors) are doing business in the TLC LASIK Centers using and operating equipment owned, upon information and belief, by the TLC LASIK Centers and, upon information and belief, engaging in doctor patient relationships with patients of TLC LASIK Centers; that further, TLC Clinical Directors are optometrists licensed and residing in the various states of the United States, including South Carolina.
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